Residence tie breaker rules determine which State deems a person resident under the tax treaty for dual residency. For individuals who are residents of both Contracting States, a sequential tie breaker applies: permanent home; if in both States, centre of vital interests; if undeterminable or no permanent home, habitual abode; if habitual abode in both or neither, nationality; if nationality is shared or absent, the competent authorities shall settle the question by mutual agreement. For persons other than individuals who are residents of both States, residence is determined by the location of the place of effective management.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Residence tie breaker rules determine which State deems a person resident under the tax treaty for dual residency.
For individuals who are residents of both Contracting States, a sequential tie breaker applies: permanent home; if in both States, centre of vital interests; if undeterminable or no permanent home, habitual abode; if habitual abode in both or neither, nationality; if nationality is shared or absent, the competent authorities shall settle the question by mutual agreement. For persons other than individuals who are residents of both States, residence is determined by the location of the place of effective management.
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